Justia Indiana Supreme Court Opinion Summaries

The child at issue in this case (Child) had a close relationship with her maternal grandparents (Grandparents) from the day she was born. The child’s mother (Mother) passed away when Child was eight years old. In accordance with Mother’s wishes, Grandparents filed for visitation rights with Child under the Grandparent Visitation Act. After a hearing, the trial court determined that it was in Child’s best interest to have a meaningful and ongoing relationship with Grandparents. Father appealed. The Supreme Court affirmed the entirety of the trial court’s order granting grandparent visitation, holding that the trial court did not abuse its discretion in awarding grandparent visitation and in setting the amount of grandparent visitation. View "In re Visitation of L-A.D.W." on Justia Law

The child at issue in this case (Child) had a close relationship with her maternal grandparents (Grandparents) from the day she was born. The child’s mother (Mother) passed away when Child was eight years old. In accordance with Mother’s wishes, Grandparents filed for visitation rights with Child under the Grandparent Visitation Act. After a hearing, the trial court determined that it was in Child’s best interest to have a meaningful and ongoing relationship with Grandparents. Father appealed. The Supreme Court affirmed the entirety of the trial court’s order granting grandparent visitation, holding that the trial court did not abuse its discretion in awarding grandparent visitation and in setting the amount of grandparent visitation. View "In re Visitation of L-A.D.W." on Justia Law

After a jury-waived trial, Defendant was found guilty of robbery and criminal confinement. The trial court used the same evidence, namely, Defendant’s act of being armed with a deadly weapon, to enhance both of his convictions from class C to class B felonies. Defendant appealed, arguing that the two convictions violated Indiana’s constitutional ban on double jeopardy because the force used to support the robbery conviction was coextensive with the force used to support the confinement conviction. The court of appeals affirmed. The Supreme Court affirmed, holding that committing two or more separate offenses each while armed with the same deadly weapon is not within the category of rules precluding the enhancement of each offense based on “the very same behavior.” View "Sistrunk v. State" on Justia Law

After a second jury trial, Defendant was convicted of child molesting as a class C felony. On appeal, Defendant challenged, among other things, the admission of testimony by a child forensic interviewer who had conducted a forensic interview of the victim that she did not observe any signs that the victim had been coached. Because Defendant did not object to this testimony, Defendant argued that the admission of the testimony was fundamental error. The Court of Appeals affirmed the convictions. The Supreme Court affirmed, holding (1) the disputed testimony was improper, as the testimony constituted impermissible indirect vouching; but (2) the error did not constitute fundamental error. View "Sampson v. State" on Justia Law

Continental Casualty Company and Twin City Fire Insurance Co. (collectively, CNA) petitioned for rehearing with respect to the Supreme Court’s opinion in this matter, Wellpoint, Inc. v. Nat’l Union Fire Ins. Co., claiming that a portion of the Court’s opinion exceeded the power granted by Trial Rule 56(B), which provides that when a party has moved for summary judgment, the court may grant summary judgment for any other party upon the issues raised by the motion even where that party does not file a motion for summary judgment. CNA argued that the Court’s opinion, which reversed the trial court’s grant of CNA’s motion for summary judgment, should not have also granted summary judgment for Wellpoint, Inc. and Anthem Insurance Companies, Inc. (collectively, Anthem) as to issues not raised by CNA’s summary judgment motion. The Supreme Court concluded that rehearing should be granted to modify its opinion to address only the issues raised in the summary judgment proceeding and modified its opinion in this case accordingly. View "Wellpoint, Inc. v. Nat’l Union Fire Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of class A felony child molesting. The court of appeals reversed Defendant’s conviction and remanded for a new trial, holding that the trial court abused its discretion in denying Defendant’s motion to compel the victim’s mother to answer a deposition question about an incident in the victim’s past and in excluding from evidence the substance of a phone conversation with the victim’s mother in which she and the victim discussed the incident. The Supreme Court granted transfer, thereby vacating the court of appeals opinion, and affirmed, holding that the trial court’s alleged errors, even if considered violations of Defendant’s Sixth Amendment right to confrontation, were harmless beyond a reasonable doubt. View "Hall v. State" on Justia Law

When Jeffrey Miller lost a job opportunity with the Indianapolis Mayor’s Office, Miller filed a complaint and multiple amended complaints, alleging that several individuals and organizations committed torts against him. Miller filed a fourth complaint adding a “JOHN DOE #8” as a defendant. The next year, Miller requested leave to file a fifth amended complaint to substitute Kristine Danz as a substitute for John Doe #8, claiming that Danz’s identity was only recently discovered during a deposition. The trial court granted Danz’s motion for summary judgment, concluding that Miller’s attempt to add Danz as a named party was barred by the two-year statute of limitations. The Supreme Court affirmed, holding that the trial court did not err in granting summary judgment in favor of Danz where the existence and identity of Danz was not unknown to Plaintiff before he commenced this action and where he waited until after expiration of the applicable statute of limitations to substitute her name for John Doe #8. View "Miller v. Danz" on Justia Law

Plaintiff, a church, filed a complaint for declaratory judgment seeking to determine the boundary line between it and Defendants, homeowners, to determine ownership of its real estate, to allow it to build a fence along the boundary line, and seeking an injunction to prevent Defendants from further trespassing. The homeowners counterclaimed, arguing that they had acquired title to the disputed real estate by adverse possession as well as prescriptive easement. The trial court granted summary judgment in favor of Defendants on both the adverse possession and prescriptive easement claims. The Supreme Court affirmed the trial court on both claims, holding that Defendants were entitled to summary judgment on their claims of adverse possession and prescriptive easement. View "Celebration Worship Ctr., Inc. v. Tucker" on Justia Law

Defendant pleaded guilty to multiple counts each of class C felony neglect of a dependent and class C felony criminal confinement. The plea agreement left sentencing to the discretion of the trial court but capped Defendant’s sentence at ten years pursuant to Ind. Code 35-50-1-2(c). This section, however, did not actually apply to Defendant. The trial court accepted the plea agreement and sentenced Defendant to ten years pursuant to the perceived statutory cap. Defendant appealed, challenging the trial court’s imposition of the aggregate sentence. The court of appeals reversed Defendant’s sentence, determining, sua sponte, that the erroneous application of section 35-50-1-2(c) rendered the plea agreement void as a matter of law. The Supreme Court granted transfer, thus vacating the decision below, and affirmed the trial court’s acceptance of Defendant’s plea agreement and its imposition of a ten-year sentence, holding that Defendant’s plea agreement was valid and enforceable despite the mistaken application of section 35-50-1-2(c). View "Russell v. State" on Justia Law

After a jury trial, Defendant was convicted of burglary, a class C felony. The Court of Appeals reversed the conviction, finding that the conviction was obtained through the State’s knowing use of perjured testimony. The Supreme Court granted transfer, thus vacating the opinion of the Court of Appeals, and affirmed the conviction, holding (1) Defendant’s due process rights were not implicated by the inconsistent testimony, as the State notified opposing counsel and the court of the conflicting testimony and proactively drew attention to the discrepancies in the testimony throughout the trial, thus permitting the jury to fully function as an informed fact finder; and (2) the incredible dubiosity rule was not applicable to this case. View "Smith v. State" on Justia Law